BBanking
EuGH schafft Klarheit: Nicht jede Weiterleitung von Geldern Dritter ist ein Zahlungsdienst im Sinne der PSD2 ECJ Clarifies the Scope of PSD2: Not Every Transfer of Third-Party Funds Constitutes a Payment Service
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  • 3 minute read

ECJ Clarifies the Scope of PSD2: Not Every Transfer of Third-Party Funds Constitutes a Payment Service

The ECJ has further clarified the distinction between payment services and other business models. The judgment confirms that merely receiving and forwarding third-party funds does not automatically trigger licensing requirements under PSD2. The decision provides greater legal certainty for FinTechs, platform operators and other businesses handling payment flows, while emphasising that the specific business model remains decisive.
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FFinTech
EUDI Wallet in the Draft Digital Identity Act (DIdG): Overview and Assessment from a Financial Sector Perspective 1
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  • 5 minute read

EUDI Wallet in the Draft Digital Identity Act (DIdG): Overview and Assessment from a Financial Sector Perspective

On 26 March 2026, the German Federal Ministry for Digital Affairs and State Modernisation published a draft bill for a Digital Identity Act (DIdG). The draft serves to implement the eIDAS Regulation at national level, as amended by Regulation, thereby further specifying the legal framework for the introduction of the EUDI Wallet in Germany.
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DData Protection
EUDI-Wallet: Chancen, offene Fragen und der Ausblick für Finanzunternehmen | ALLES LEGAL #124 EUDI-Wallet: Opportunities, Open Questions and Outlook for Financial Institutions
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  • 2 minute read

EUDI-Wallet: Opportunities, Open Questions and Outlook for Financial Institutions | ALLES LEGAL #124

In the fifth and final episode of our EUDI-Wallet series, Peter Frey, partner at Annerton, and host Dana Wondra (Payment & Banking) discuss the key findings and challenges surrounding the European Digital Identity Wallet. Topics include opportunities for financial institutions, legal uncertainties, technical requirements and political momentum.
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DDORA & IT Security
The new DORA-RTS SUB is here! 5
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  • 4 minute read

The new DORA-RTS SUB is here!

On 2 July 2025, the European Commission adopted the Regulatory Technical Standard RTS SUB (Delegated Regulation (EU) 2025/532). It specifies the requirements that financial institutions must meet when (sub-)contracting ICT services that support critical or important functions – particularly with regard to risk assessment and the management of sub-service providers.
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